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Text of Second Circuit Opinion: Extent of Plan's Compliance with DOL Claims Procedure Regulation Determines Court's Standard of Review (PDF)
U.S. Court of Appeals for the Second Circuit
Apr. 13, 2016
"[We] hold that, when denying a claim for benefits, a plan's failure to comply with the [DOL]'s claims-procedure regulation, 29 C.F.R. Section 2560.503-1, will result in that claim being reviewed de novo in federal court, unless the plan has otherwise established procedures in full conformity with the regulation and can show that its failure to comply with the regulation in the processing of a particular claim was inadvertent and harmless. We further hold that civil penalties are not available to a participant or beneficiary for a plan's failure to comply with the claims ‐ procedure regulation. Finally, we hold that a plan's failure to comply with the claims-procedure regulation may, in the district court's discretion, constitute good cause warranting the introduction of additional evidence outside the administrative record." [Halo v. Yale Health Plan, No. 14-4055 (2d Cir. Apr. 12, 2016)]
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